Does a Ningxia silicomanganese exporter need to give CBAM data to EU buyers?
No CBAM figure is due. Silicomanganese, declared under CN 7202 30, is not in Annex I; the only ferro-alloys covered are ferro-manganese, ferro-chromium and ferro-nickel. EU steelmakers may still ask for a product footprint, which is a commercial request.
Covered and not covered
- Covered: ferro-manganese (7202 1), ferro-chromium (7202 4) and ferro-nickel (7202 6).
- Not covered: silicomanganese (7202 30), ferrosilicon (7202 21 and 7202 29) and other 7202 alloys.
Why buyers still ask
EU steel mills build product footprints for their own customers and count purchased alloys in Scope 3. A footprint per tonne covering coke, electrodes and electricity answers that request.
Plants that make both
If the same furnaces switch to ferro-manganese for EU orders, that product is covered. Keep production and fuel records per campaign so the covered product can be shown on its own.
What Senseible does here
Senseible reads fuel, electricity and production documents into dated, fingerprinted installation records, the starting point for the actual emissions an EU importer asks for.
Sources: CBAM Regulation (EU) 2023/956, consolidated, European Commission, CBAM legislation and guidance, Implementing Regulation (EU) 2023/1773, monitoring rules
Last reviewed 2026-10-22.